Joe Anthony Martinez, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court affirmed the petitioner's first-degree murder conviction under a complicity theory. It held that plain-error review applied because trial counsel objected to the deliberation instruction on a different ground and failed to identify its legal defect; the error was not plain because the evidence of deliberation was overwhelming and the instructions, read as a whole, adequately stated the law. The court also held that sufficient evidence supported the conviction because the petitioner participated in actions indicating both deliberation and intent to facilitate the killing.